State of New Hampshire v. Purdue Pharma L.P. et al

Filing 1

NOTICE OF REMOVAL from Merrimack County Superior Court, NH, case number 217-2017-CV-00402 (filing fee $400, receipt number 0102-1561627) filed by The Purdue Frederick Company Inc., Purdue Pharma Inc., Purdue Pharma L.P.. Answer Follow Up on 10/6/2017. The court only follow up date DOES NOT include 3 additional days that may apply per FRCP 6(d) and FRCrP 45(c). State Court Record Follow Up 9/29/2017. (Attachments: # 1 Exhibit A: State Court Docket and Redacted Complaint, # 2 Exhibit B: Notice of Conventional Filing, # 3 Exhibit C: Notice of Removal to Counsel, # 4 Exhibit D: Notice of Removal to State Court, # 5 Civil Cover Sheet) Complaint includes a claim under the NH Consumer Protection Act. A copy of the Complaint has been sent to the NH Attorney General via an automatic Notice of Electronic filing.(Deane, W.)

EXHIBIT D

THE STA1E OF NEW HAMPSHIRE
MERRIMACK, SS.

SUPERIOR COURT
State of New Hampshire
v.
Purdue Pharma L.P.;
Purdue Pharma Inc.; and
The Purdue Frederick Company Inc.
Case No. 217-2017-CV-00402

NOTICE OF FILING OF NOTICE OF REMOVAL (TO STATE COURT)
PLEASE TAKE NOTICE that on September 15, 2017, pursuant to the provisions of Title
28 U.S.0 §§ 1331, 1332, 1441, 1446, and 1453, the Defendants Purdue Pharma L.P., Purdue
Pharma Inc., and The Purdue Frederick Company Inc. (collectively, "Purdue"), by and through
their counsel, Nixon Peabody LLP, filed in the United States District Court for the District of
New Hampshire a Notice of Removal of the above-captioned action. Pursuant to 28 U.S.C. §
1446(d), a true and correct copy of the Notice of Removal, attached hereto as EXHIBIT A, is
provided to this Court and all parties to this proceeding.
The filing of the attached Notice of Removal has effected the removal of the abovecaptioned action and this Court should not take any further action with respect to this case
"unless and until the case is remanded." 28 U.S.C. § 1446(d).

Respectfully Submitted,
Purdue Pharma L.P.;
Purdue Phanna Inc.; and
The Purdue Frederick Company Inc.
By and Through Their Attorneys,
NIXON PEABODY LLP
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4833-3086-9327.1

Dated: September 15, 2017
W. Daniel Deane, Esq.
NH Bar No. 18700
David A. Vicinanzo, Esq.
NH Bar No. 9403
Nixon Peabody LLP
900 Elm Street, 14th Floor
Manchester, NH 03101
T: [phone]
[e-mail]
dcieane(cOixon.peabody.com
CERTIFICATE OF SERVICE
I hereby certify that on this 15th day of September, 2017, a copy of the foregoing Notice
of Filing of Notice of Removal (to State Court) was served via e-mail and by United States firstclass mail, postage prepaid, to the following counsel of record:
James T. Boffetti, Esq.
Senior Assistant Attorney General
Chief, Consumer Protection
and Antitrust Bureau
Department of Justice
33 Capitol Street
Concord, NH 03301
james.boffett ,a.cioj.nh.gov

Linda J. Singer, Esq.
Motley Rice LLC
401 9t11 Street NW, Suite 1001.
Washington, D.C. 20004
Isingen&motleyrice.con,

.,
--`,------------W. Wniel Deane, Esq.

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4833-3086-9327.1